Mangubat v. Sandiganbayan
REITERATIONFacts
The Antecedents: The underlying dispute involved multiple criminal cases before the Sandiganbayan, in which the prosecution sought to utilize several accused individuals as state witnesses. A key point of contention arose regarding Delia Preagido, one of the proposed state witnesses, whose discharge was opposed by some defendants. The basis for this opposition was Preagido's prior conviction in other cases for estafa through falsification of public/commercial documents, although she had appealed these convictions to the Supreme Court. Procedural History: The prosecution filed a motion to discharge three accused, including Delia Preagido, to serve as state witnesses under Section 9, Rule 119 of the Rules of Court. Despite the opposition based on Preagido's prior convictions, the Sandiganbayan, by a March 5, 1982 order, overruled the opposition and directed her discharge, reasoning that her appeals were pending and she retained the presumption of innocence. Preagido then provided direct testimony, with cross-examination deferred to allow the defense to challenge the Sandiganbayan's actions before the Supreme Court. This challenge led to the instant action. Notably, Preagido's appeal was not finally resolved until November 12, 1985, after the Supreme Court had already dismissed the petition at bar on April 20, 1985. The Petition: The petitioners sought reconsideration of the Supreme Court's April 20, 1985 decision, which had declined to nullify the Sandiganbayan's resolution. They argued that Delia Preagido was disqualified from becoming a state witness due to her conviction of crimes involving moral turpitude, asserting this qualification was as crucial as the necessity of her testimony. The Supreme Court, in its resolution, denied the motion for reconsideration, affirming that the Sandiganbayan did not act with grave abuse of discretion in discharging Preagido, given that her appeal was pending and she was presumed innocent until final conviction. The Court further noted that her discharge operated as an acquittal, precluding her return to accused status, and that any error in her discharge did not render her incompetent as a witness or her testimony inadmissible.
Issue(s)
Whether the Sandiganbayan committed grave abuse of discretion correctible by certiorari in ordering the discharge of Delia Preagido as a state witness despite her pending appeals from prior convictions for crimes involving moral turpitude. Whether the prior conviction of Delia Preagido, even with a pending appeal, disqualified her from being discharged as a state witness.
Ruling
The Court resolved to deny the motion for reconsideration and to declare the denial final. The Sandiganbayan's resolution ordering the discharge of Delia Preagido as a state witness was upheld, and the previous decision declining to nullify it was affirmed.
Ratio Decidendi
On Issue 1: The Court held that the Sandiganbayan did not commit grave abuse of discretion, correctible by certiorari, in ordering the discharge of Delia Preagido as a state witness. At the time of the discharge order (March 5, 1982), Preagido's appeals from her convictions for crimes involving moral turpitude were still pending before the Supreme Court. The Sandiganbayan correctly applied the constitutional presumption of innocence, stating that until a promulgation of final conviction is made, this mandate prevails. This ruling was found to be not bereft of legal or logical foundation and could not be characterized as a whimsical or capricious exercise of judgment. The Court cited Alafriz v. Nable and Sichangco v. Board of Commissioners of Immigration in support of this principle. On Issue 2: The Court clarified that even if the Sandiganbayan's order for discharge was considered erroneous due to the pending appeals from convictions involving moral turpitude, this error does not render Delia Preagido incompetent as a witness or her testimony totally untrustworthy, although it may warrant caution in its assessment. The Court emphasized that the act of discharging Preagido as a state witness, having testified as such, operated as an acquittal under Section 11, Rule 119 of the Rules of Court, forever precluding her reinclusion as a defendant in the cases from which she was discharged or being charged anew for the same offenses. This is settled law, as affirmed in cases like People v. Taruc and Bernardo v. del Rosario. Furthermore, the Court noted that Preagido was not incompetent to testify even without being discharged, and the correctness of the trial court's determination regarding the grounds for discharge affects only the discharged person's criminal liability, not their competency as a witness or the admissibility of their testimony. The testimony of a state witness is subject to the same objections and standards of assessment as any other witness.
Main Doctrine
The Supreme Court reiterated that the Sandiganbayan did not commit grave abuse of discretion in ordering the discharge of Delia Preagido as a state witness, despite her pending appeals from prior convictions. The Court emphasized that the constitutional presumption of innocence prevails until final conviction. Moreover, the resolution affirmed that once an accused is discharged as a state witness under Section 9, Rule 119, and testifies, this operates as an acquittal, precluding their re-inclusion as a defendant or being charged anew for the same offenses, regardless of subsequent adverse rulings on their appeals.